The Code of Practice on Taxation for Banks: Annual Report 2025
Published 11 December 2025
© Crown copyright 2025
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1. Introduction
The Code of Practice on Taxation for Banks (‘the Code’) helps to deliver HM Revenue and Customs’ (HMRC) objective of promoting compliance. It was introduced in 2009 to change the attitudes and behaviours of banks towards avoidance because of their unique position as potential users, promoters and funders of tax avoidance.
To strengthen the Code and provide greater transparency, legislation was introduced in Finance Act 2014 which requires HMRC to publish an annual report on how the Code is operating.
The Code describes the approach expected of banks with regard to governance, tax planning and engagement with HMRC. Banks operating in the UK that sign up to the Code commit to adopt good practices in relation to their own tax affairs, and not to promote tax avoidance by others. The Code sets out that banks should:
- adopt adequate governance to control the types of transactions they enter into
- not undertake tax planning that aims to achieve a tax result that is contrary to the intentions of Parliament
- comply fully with all their tax obligations
- maintain a transparent relationship with HMRC
Where HMRC has concerns over whether a bank has met its obligations under the Code, HMRC will take action to address these concerns in line with the published Governance Protocol (‘the Protocol’).
HMRC may name in the annual report banks that are found not to have complied with their Code commitments. A bank can only be named once all the steps set out in the Protocol have been completed.
2. Operation of the Code in the year ended 31 March 2025
Overview
This is the annual report on the operation of the Code, covering the period 1 April 2024 to 31 March 2025 (‘the Period’).
The names of the 314 banks that had adopted the Code as at 31 March 2025 are listed at Annex A. The list includes:
- 307 banks that had adopted the Code at 31 March 2024
- 7 banks which adopted in the year ended 31 March 2025
Four of the 311 banks which were listed as adopters as at 31 March 2024 were not in the Code population [footnote 1] as at 31 March 2025 because they had ceased all banking activity, or were acquired by other banks in the Code population.
The 6 banks within the Code population that had not adopted the Code as at 31 March 2025 are listed at Annex B. This list is drawn from banks which HMRC’s records show to be within the charge to the Bank Levy (whether or not they have any liability for the Period), and from the list of banks and building societies published by the Prudential Regulation Authority.
The Code continues successfully to promote positive behaviours across the banking sector:
- none of the banks which had adopted the Code by 31 March 2025 has been determined to be in breach of the Code during the Period
- banks that had adopted the Code did not make any disclosures under the Disclosure of Tax Avoidance Schemes regime in the Period
- all transactions for which a review was completed in the Period, during risk assessments, were considered to be Code compliant [footnote 2]
- no initial concerns were escalated to Director level or beyond during the Period [footnote 3]
HMRC’s guidance on the Code can be found in the Banking Manual.
HMRC’s compliance work with banks
HMRC’s Large Business directorate manages the tax compliance of the largest banks and several smaller banks that are part of large non-banking groups. This includes 73 of the banks within the Code population. HMRC’s Wealthy and Mid-Sized Business Compliance directorate manages the tax compliance of smaller banks.
HMRC manages the tax compliance of the largest businesses through the Business Risk Review (BRR+) process. More information on this process can be found in HMRC’s internal manual Tax Compliance Risk Management. Thirty-five banking groups dealt with in Large Business directorate had a BRR+ during the Period. All customers not receiving a BRR+ during the Period have had the opportunity to hold an annual conversation with HMRC to discuss business developments and raise any issues.
Banks in Large Business that sign up to the Code are subject to an enhanced BRR+ process, under which the banks’ compliance with the Code is reviewed.
The 4 Code categories on the BRR+ template are:
- the bank’s compliance with the Code has been reviewed and there are no current concerns
- the bank’s compliance with the Code is under review
- there are initial concerns over the bank’s compliance with its Code commitments [footnote 4]
- there is an interim view that the bank has breached the Code [footnote 5]
At the end of the Period, 2 banks in Large Business were under review as a part of the BRR+ process. One bank remains under review, while the other was found to be compliant with its Code commitments. All other reviews under the BRR+ process conducted during the Period were noted to have no current concerns. If HMRC discovers any issues that give rise to initial concerns, it will escalate them in accordance with the Protocol.
The tax compliance of smaller banks is managed by the Wealthy and Mid-Sized Business Compliance directorate team. For these banks:
- during formal enquiries HMRC emphasises the Code obligation to ‘maintain a transparent relationship with HMRC’ in order to resolve matters quickly and efficiently
- outside the formal enquiry process HMRC raises Code compliance when meeting the representatives of smaller banks in order to ensure they are aware of and meet their obligations under the Code
- generally the banks that the team have interacted with during the year have had an open and transparent relationship with HMRC
At the end of the Period, one smaller bank was under review. This bank remains under review.
Large Business directorate and Wealthy and Mid-Sized Business Compliance directorate customer teams may also identify concerns about a bank’s governance, its approach to tax planning or the transparency of its relationship with HMRC during enquiries or other interactions through the year. If so, these are addressed in accordance with the Protocol.
If potential issues involving a bank are identified during compliance work on other customers, HMRC considers whether the available evidence gives rise to concerns about the bank’s compliance with its Code commitments. Where it does, HMRC will investigate the bank’s compliance with all aspects of the Code. Any suspected breaches will be dealt with robustly, in accordance with the Protocol.
HMRC’s response to Code approaches
HMRC encourages banks to discuss any proposed transaction where, on the bank’s analysis, there is a tax result that may be contrary to the intentions of Parliament.
In the Period, HMRC received no pre-transaction Code approaches involving any uncertainty around the intentions of Parliament.
Where HMRC considers there to be no identifiable uncertainty around the intentions of Parliament, HMRC may decline to provide a view. There were no instances of this in the Period.
The absence of any Code approaches continues a trend from previous years. HMRC believes that there are a range of factors that have led to fewer approaches by banks, including a better understanding of the Code, and a continuing evolution in attitudes to tax avoidance.
Annex A: Banks that had adopted the Code at 31 March 2025
This is a list of banks, building societies and other financial institutions known as ‘banks’ adopting or readopting The Code of Practice on Taxation for Banks at 31 March 2025.
It includes all banks that have unconditionally adopted or readopted the Code. Adoption will cover all of a group’s operations in the UK and, in the majority of cases, only an agreed principal name for the overall adopting group is shown.
Where requested HMRC has agreed to include names in addition to the principal group name if:
- the names on the Prudential Regulation Authority lists are so different that it would not be obvious that they are connected and covered by the same adoption
- a group operating in the UK does so through separately named and independently managed entities and their names are so different that it would not be obvious that they are connected
| Aareal Bank AG | |
| ABC International Bank plc | |
| ABN AMRO UK Group | |
| Access Bank UK Ltd, The | |
| Adyen N.V.: adopted the Code in the period this report covers. | |
| Afin Bank Limited: adopted the Code in the period this report covers. | |
| Agricultural Bank of China Ltd London Branch | |
| Al Rayan Bank | |
| Alba Bank Limited: previously AlbaCo Limited | |
| Aldermore Bank plc | |
| Allfunds Bank SAU | |
| Allica Bank Ltd | |
| Allied Irish Banks plc Group: adoption includes AIB Group (UK) plc | |
| Alpha Bank London Limited | |
| ANZ Banking Group | |
| Arab National Bank | |
| Arbuthnot Banking Group plc | |
| Atom Bank plc | |
| Axis Bank UK Ltd | |
| Banco Bilbao Vizcaya Argentaria SA London Branch | |
| Banco Bradesco Europa SA | |
| Banco de Sabadell SA - London Branch | |
| Banco do Brasil SA - London Branch | |
| Bangkok Bank Public Co Ltd | |
| Bank Frick & Co AG | |
| Bank J. Safra Sarasin (Gibraltar) Ltd | |
| Bank Leumi (UK) plc | |
| Bank Mandiri (Europe) Ltd | |
| Bank of Africa United Kingdom plc | |
| Bank of America Group | |
| Bank of Baroda | |
| Bank of Baroda (UK) Ltd | |
| Bank of Beirut (UK) Ltd | |
| Bank of Ceylon (UK) Ltd | |
| Bank of China | |
| Bank of Communications Co Ltd London Branch | |
| Bank of India | |
| Bank of Ireland | |
| Bank of London and The Middle East plc | |
| Bank of London Group Limited, The | |
| Bank of Montreal | |
| Bank of New York Mellon (UK Group) | |
| Bank of Nova Scotia, London Branch: adoption includes Scotiabank | |
| Bank of Taiwan - London Branch | |
| Bank of the Philippine Islands (Europe) plc | |
| Bank Pictet & Cie (Europe) AG, London Branch | |
| Bank Saderat plc | |
| Bank Sepah International plc | |
| Banking Circle SA | |
| Banque Banorient France | |
| Banque Transatlantique SA London Branch | |
| Barclays Bank | |
| Bath Investment & Building Society | |
| BAWAG PSK International | |
| Bayerische Landesbank - London Branch | |
| BB Securities Ltd | |
| Beverley Building Society | |
| Birmingham Bank Ltd | |
| BNF Bank plc | |
| BNP Paribas | |
| British Arab Commercial Bank plc | |
| Brown Shipley | |
| Buckinghamshire Building Society | |
| Byblos Bank Europe SA | |
| C Hoare & Co | |
| CAF Bank | |
| Caixabank SA | |
| Cambridge & Counties Bank Ltd | |
| Cambridge Building Society | |
| Canadian Imperial Bank of Commerce | |
| Canara Bank | |
| Carnegie Investment Bank AB | |
| Castle Trust Capital plc | |
| Cecabank SA | |
| Chang Hwa Commercial Bank Ltd - London Branch | |
| Charity Bank Ltd, The | |
| Charter Savings Bank | |
| Chetwood Financial Ltd | |
| Chiba Bank Ltd - London Branch, The | |
| China Citic Bank Corporation Limited - London Branch | |
| China Construction Bank Corporation London Branch | |
| China Merchants Bank Co Ltd | |
| China Minsheng Banking Corporation Limited London Branch: adopted the Code in the period this report covers. | |
| Chorley and District Building Society, The | |
| CIMB Bank Berhad - London Branch | |
| Citadel Securities (Europe) Ltd | |
| Citi | |
| ClearBank Ltd | |
| Clearstream Banking SA | |
| Close Brothers Group plc | |
| Commerzbank AG | |
| Commonwealth Bank of Australia, The | |
| Conister Bank: adopted the Code in the period this report covers. | |
| Co-operative Bank plc, The | |
| Coventry Building Society | |
| Crédit Agricole Group | |
| Crédit Industriel et Commercial Group | |
| Crown Agents Bank Ltd | |
| Cumberland Building Society | |
| Cynergy Bank Plc: previously Cynergy Bank Limited | |
| Daiwa Capital Markets Europe Ltd: adoption includes Daiwa Corporate Advisory Ltd, Daiwa Corporate Advisory Holdings Ltd and Daiwa Asset Management (Europe) Ltd | |
| Danske Bank A/S: adoption includes Northern Bank Ltd | |
| Darlington Building Society | |
| DBS Bank Ltd | |
| DekaBank Deutsche Girozentrale | |
| Deutsche Bank AG | |
| Deutsche Pfandbriefbank AG | |
| DF Capital Bank Ltd | |
| DNB Bank ASA | |
| Dudley Building Society | |
| DZ Bank | |
| Earl Shilton Building Society | |
| Ecology Building Society | |
| EFG Private Bank Ltd | |
| Emirates NBD Bank (P.J.S.C) | |
| Eurobank Private Bank Luxembourg SA London Branch | |
| Europe Arab Bank plc | |
| Export-Import Bank of India | |
| FCE Bank plc | |
| FCMB Bank (UK) Ltd | |
| FidBank UK Limited | |
| First Abu Dhabi Bank P.J.S.C | |
| First Commercial Bank - London Branch | |
| FirstBank UK Limited | |
| FirstRand Bank Limited | |
| Furness Building Society | |
| Gatehouse Bank plc | |
| GB Bank Limited | |
| Genclose Limited: previously Masthaven Limited | |
| GH Vive Limited | |
| Ghana International Bank plc | |
| Goldman Sachs | |
| Griffin Bank Limited | |
| Guaranty Trust Bank (UK) Ltd | |
| Gulf International Bank (UK) Ltd | |
| Gulf International Bank BSC (London Branch) | |
| Habib Bank Zurich plc | |
| Haitong Bank, SA | |
| Hampden & Co plc | |
| Hampshire Trust Bank plc | |
| Handelsbanken plc | |
| Hanley Economic Building Society | |
| Harpenden Building Society | |
| Havin Bank Ltd | |
| HBL Bank UK Limited | |
| Hinckley & Rugby Building Society | |
| HSBC Holdings plc | |
| HTB Leasing & Finance Ltd: previously Wesleyan Bank Ltd | |
| Hua Nan Commercial Bank Ltd - London Branch | |
| ICBC (London) plc | |
| ICBC Ltd London Branch | |
| ICBC Standard Bank plc | |
| ICICI Bank UK Plc | |
| IFAST Global Bank Limited | |
| Ikano Bank AB | |
| Industrial Bank of Korea - London Branch | |
| ING | |
| Intesa Sanpaolo S.p.A. - London Branch | |
| Investec plc | |
| Itau BBA International plc | |
| Jefferies International Ltd | |
| JN Bank UK Ltd | |
| John Deere Bank SA | |
| Jordan International Bank plc | |
| JP Morgan | |
| Julian Hodge Bank Ltd | |
| KBC UK Banking Group: adoption includes KBC Bank NV - London Branch and KBC Investments Ltd | |
| KEB Hana Bank | |
| Kexim Bank (UK) Ltd | |
| KfW IPEX-Bank GmbH - London Branch | |
| Kingdom Bank Ltd | |
| Klarna AB | |
| Kookmin Bank Co Ltd London Branch | |
| Korea Development Bank – London Branch, The | |
| Kroo Limited | |
| Kuwait Finance House Plc: previously Ahli United Bank (UK) plc | |
| Landesbank Baden-Wϋrttemberg | |
| Landesbank Hessen-Thüringen Girozentrale (London Branch) | |
| Leeds Building Society | |
| Leek United Building Society | |
| LHV Bank Limited | |
| Lloyds Banking Group plc: adoption includes Lloyds Bank plc and Bank of Scotland plc (including Halifax) | |
| Lombard Odier (Europe) SA | |
| Loughborough Building Society | |
| Macquarie Group | |
| Malayan Banking Berhad | |
| Mansfield Building Society | |
| Market Harborough Building Society | |
| Marsden Building Society | |
| Mashreq Bank Psc - London branch | |
| Mediobanca - Banca di Credito - London branch | |
| Mega International Commercial Bank Co., Limited | |
| Melli Bank plc | |
| Melton Mowbray Building Society | |
| Methodist Chapel Aid Ltd | |
| Metro Bank plc | |
| Mirabaud and Cie (Europe) SA UK Branch | |
| Mitsubishi UFJ Financial Group: adoption includes Mitsubishi UFJ Securities International plc, The MUFG Bank Ltd, Mitsubishi UFJ Trust & Banking Corporation - London Branch, Mitsubishi UFJ Trust International Ltd and Mitsubishi UFJ Asset Management (UK) Ltd | |
| Mizrahi Tefahot Bank Ltd | |
| Mizuho UK Banking Group: adoption includes Mizuho International plc, Mizuho Bank - London Branch and Mizuho Capital Markets (UK) Ltd | |
| Monmouthshire Building Society | |
| Monument Bank Limited | |
| Monzo Bank Ltd | |
| Morgan Stanley | |
| Nacional Financiera SNC - London Branch | |
| National Australia Bank Ltd | |
| National Bank Financial Inc UK Branch | |
| National Bank Of Canada - London Branch | |
| National Bank of Egypt (UK) Ltd | |
| National Bank of Greece UK: adoption includes National Bank of Greece SA London Branch, NBGI Private Equity Ltd, NBG International Ltd, NBG GP Ltd, NBG Finance plc, NBG Finance (Dollar) plc and NBG Finance (Sterling) plc | |
| National Bank of Kuwait (International) plc | |
| National Counties Building Society | |
| Nationwide Building Society: adoption includes Clydesdale Bank plc (trading as ‘Virgin Money’, covering the ‘Yorkshire Bank’ brand) | |
| Natixis | |
| NatWest Group | |
| Nedbank | |
| Newbury Building Society | |
| Newcastle Building Society: adoption includes Manchester Building Society | |
| NIBC Bank NV | |
| Noble Grossart Holdings Ltd | |
| Nomura UK Group | |
| NORD/LB Group: adoption includes NORD/LB Norddeutsche Landesbank Girozentrale and Deutsche Hypothekenbank Aktiengesellschaft | |
| Nordea Bank Abp | |
| Norinchukin Bank - London Branch, The | |
| Northern Trust Company, The | |
| Nottingham Building Society | |
| OakNorth Bank Plc | |
| OneSavings Bank plc | |
| Oversea-Chinese Banking Corporation - London Branch | |
| Oxbury Bank plc | |
| Paragon Banking Group plc | |
| PCF Bank Ltd | |
| Penrith Building Society | |
| Perenna Bank Plc | |
| Persia International Bank Plc | |
| Philippine National Bank (Europe) plc | |
| Principality Building Society | |
| Progressive Building Society | |
| PT Bank Negara Indonesia (Persero) Tbk - London Branch | |
| Punjab National Bank (International) Ltd | |
| Qatar National Bank (Q.P.S.C) | |
| QIB (UK) plc | |
| Rabobank | |
| Raiffeisen Bank International AG - London branch | |
| Rathbone Brothers plc | |
| RCI Bank UK Ltd | |
| Recognise Bank Limited | |
| Redwood Bank Ltd | |
| Reliance Bank Ltd | |
| Revolut NewCo UK Limited: adopted the Code in the period this report covers. | |
| Riyad Bank - London Branch | |
| Royal Bank of Canada | |
| Saffron Building Society | |
| Sainsbury’s Bank plc | |
| Santander | |
| Schroders plc | |
| Scottish Building Society | |
| Secure Trust Bank | |
| Shanghai Commercial Bank Ltd | |
| Shanghai Pudong Development Bank Co Ltd | |
| Shawbrook Bank Ltd | |
| Shinhan Bank - London Branch | |
| Siemens Bank GmbH | |
| SilverRock Bank Limited: adopted the Code in the period this report covers. | |
| Skandinaviska Enskilda Banken AB | |
| Skipton Building Society | |
| SMBC Bank international plc | |
| Société Générale: adoption includes Kleinwort Benson | |
| Sonali Bangladesh (UK) Limited | |
| Stafford Railway Building Society | |
| Standard Chartered Bank | |
| Starling Bank Ltd | |
| State Bank of India | |
| State Bank of India (UK) Ltd | |
| State Street | |
| Streambank plc | |
| Suffolk Building Society | |
| Sumitomo Mitsui Trust Bank Ltd | |
| Swansea Building Society | |
| T.C.Ziraat Bankasi A.S. | |
| Tandem Bank Ltd | |
| TD Bank Group | |
| Teachers Building Society | |
| The Bank of East Asia Limited | |
| The CTB Finance plc | |
| Tipton & Coseley Building Society | |
| Triodos Bank UK Ltd | |
| TSB Banking Group and Subsidiaries (TSB Group): adoption includes TSB Banking Group, TSB Bank plc, TSB Scotland Nominees Ltd, TSB Scotland (Investment) Nominees Ltd. | |
| Turkish Bank (UK) Ltd | |
| Turkiye Is Bankasi AS - London Branch | |
| U.S. Bank Europe DAC: previously Elavon Financial Services Designated Activity Company | |
| UBS AG | |
| UniCredit Banking Group | |
| Union Bancaire Privée UBP SA | |
| Union Bank of India (UK) Ltd | |
| United Bank for Africa (UK) Ltd | |
| United National Bank Ltd | |
| United Overseas Bank Ltd | |
| United Trust Bank Ltd | |
| Unity Trust Bank plc | |
| Vanquis Banking Group | |
| Vernon Building Society | |
| Vida Bank Limited : adopted the Code in the period this report covers. | |
| VTB Capital plc | |
| Weatherbys Bank Ltd | |
| Wells Fargo & Co | |
| West Bromwich Building Society | |
| Westpac Banking Corp - London | |
| Woori Bank - London Branch | |
| Wyelands Bank plc | |
| Yorkshire Building Society | |
| Zempler Bank Limited: previously Advanced Payment Solutions Limited | |
| Zenith Bank (UK) Ltd | |
| Zopa Bank Ltd |
Banks that are no longer adopters of the Code and acquisitions
| Banque Havilland SA: ceased trading before 31 March 2025 |
| Clydesdale Bank plc: adoption includes Virgin Money, Yorkshire Bank; acquired by Nationwide Building Society and is included in their adoption. |
| Tesco Bank: the Tesco Bank business was acquired by Barclays Bank on 1 November 2024 and is included in their adoption. Tesco Personal Finance Ltd is no longer within the Code population. |
| Western Union International Bank Gmbh: ceased trading before 31 March 2025 |
Annex B: Banks that had not adopted the Code at 31 March 2025
The list is drawn from banks that HMRC know to be in the Bank Levy population (ignoring the £20 billion threshold) and banks on the list of banks and building societies at 31 March 2025 as published by the Prudential Regulation Authority.
| BGC Brokers L.P. |
| Cantor Fitzgerald Europe |
| Gibraltar International Bank Limited |
| Moneycorp Bank Limited |
| Trusted Novus Bank Limited |
| Xapo Bank Limited |
Banks that are no longer in scope of the Code which previously had not adopted the Code
| Ashman Finance Limited: no longer within the Code population |
| Fiinu 2 Limited: no longer within the Code population |
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As defined in Section 285(4) to (6), Finance Act 2014. ↩
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Risk assessments conducted as part of BRRs are reviewed after the reporting period and confirmed with Customer Compliance Managers to provide assurance over their Code compliance. ↩
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The Governance Protocol has 4 levels of escalation. The first level of escalation is to directors of HMRC and board level of the bank. HMRC’s process for dealing with concerns is set out in detail at BKM506100 to BKM506900 of the guidance. ↩
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A bank will only be included in this category where Senior Civil Servants in HMRC’s Large Business and Business, Assets and International directorates have given approval to discuss the concerns with the bank. ↩
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A bank will only be included in this category when the case has been considered by the Tax Disputes Resolution Board and the Board have concluded that the bank has breached the Code. ↩